Preparing for RIS: why European retail platforms need usage-based ETF governance analytics
The EU Retail Investment Strategy (RIS) raises the bar on value for money and distributor oversight. This is a summary of our white paper on what it means for retail brokers, neobrokers and investing apps, and why independent usage data is becoming a useful part of the evidence they keep.
Where RIS stands
Council and Parliament reached a provisional agreement on 18 December 2025. Formal adoption is still pending: the Parliament committee approved the text on 23 June 2026, and the plenary vote is forecast for 11 November 2026, so the timing of publication in the Official Journal is not yet fixed. Under the agreement most rules apply 30 months after publication (the PRIIPs rules after 18 months), which on current timing points to around mid-2029. Firms should check the final published text.
What it asks of manufacturers and distributors
Manufacturers must show that costs and charges are justified against relevant peer groups. For ETFs, that duty sits with the UCITS management company, and ETFs are not treated separately. Distributors build on existing MiFID II product governance: they must identify additional distribution costs and inducements, check that the product remains consistent with its target market, and feed their findings back to the manufacturer.
On inducements, the agreed text does not impose an EU-wide ban on inducements. It introduces a stricter test, with a tangible client benefit and inducement costs disclosed clearly and separately, and member states may impose their own restrictions or bans.
The end of payment for order flow
Article 39a of MiFIR, introduced by Regulation (EU) 2024/791, prohibits payment for order flow (PFOF) for retail clients. It entered into force on 28 March 2024. Germany was the only member state to use the transitional exemption, which allowed it until 30 June 2026, so the ban has applied in every member state since 1 July 2026. As this revenue source falls away, platforms are looking harder at product shelf optimisation, governance efficiency and their relationships with issuers.
Why TER alone is no longer enough
A low total expense ratio does not by itself show that a product delivers fair value. A fuller view includes spreads and execution costs, tracking difference and tracking error, turnover and implicit transaction costs, securities lending revenue offsets, replication complexity, and how clients actually hold and switch the product.
The data gap
Most platforms hold strong internal data on transactions, flows, holdings and savings plans. What they usually lack is a cross-platform benchmark showing how a product is adopted, retained and used across the wider retail market. A single platform's data cannot provide that context on its own.
How usage-based analytics can help
- Value-for-money reviews and shelf decisions informed by peer adoption and retention.
- Spotting products used outside their intended target market, or with unusually short holding periods.
- Evidence-based conversations with ETF issuers.
- Structured documentation for governance committees and periodic reviews.
No rule currently requires firms to use usage analytics. The case for them is that they can help firms evidence their governance processes.
Contribute to the dataset
ETF Explorers aggregates anonymised, ISIN-level ETF usage data from European retail platforms. Contributing platforms see how they compare with their peers. Get in touch to find out more.